Health and safety program success is in the details

Also see:
• Health and safety success starts with a plan
• Management needs to be on board with health and safety plan
• Z10 the benchmark for safety standards

By Bob Carruth
Risk Control Manager

Editor's note: This article is the fourth in a series that provides a primer for ANSI Z10, the voluntary consensus standard for health and safety management systems approved in 2005. The first three articles are available online at www.ncacc.org/rmp.htm.

In previous articles laying out the details of ANSI Z10, I discussed the importance of management support, employee participation, and risk assessment goal determination for the organization's Occupational Health and Safety Management System (or OHSMS). In the next two articles, I will outline the "meat and potatoes" of management. This month, we will focus on the operational elements of the OHSMS; next month, we will discuss training, communications and documentation.

As I discuss the operational elements of this management system, it is important to note the gaps that may be in your own system so that you can make sure these areas are addressed adequately.

Hierarchy of controls: Once a hazard or risk has been identified, what do you do about it? If left uncontrolled, you are banking on pure chance for prevention. This can be catastrophic for the organization, both from a financial as well as an emotional and psychological perspective. Uncontrolled hazards will, over time, also have a profound effect on employee morale and relations. Simply put, any hazard or exposure that is identified should be addressed in the following priority order, until the highest feasible control can be identified: elimination, substitution, engineering controls, warnings, administrative controls, and personal protective equipment.

Notice the order of these move from less dependence of human behavior to more; this can also lead to a less-than-effective solution to the problem and increase the chances of an incident occurring. Implementation of the control should also be done in light of overall cost investment, as well as feasibility of the proposed solution.

Design review and management of change: This is usually the most overlooked – and most important – aspect of an organization's OHSMS. This is particularly true of operations where a lot of change may take place over time. Often, a new process or technology is introduced into the workplace, or a program or process is restarted. In both of these situations, it is much easier to identify throughout the planning process those areas that may increase risk for the organization, and design the process to include safety and risk considerations.

Procurement: The first line of defense in any organization is with the person (or persons) responsible for purchasing the materials, tools and/or items used by the organization. The purchasing staff should be fully aware and trained on recognizing hazardous materials and know how to advise employees on less hazardous substitutions. In addition, the purchasing agent is also the critical link in getting the required documentation, whether it be MSDSs for chemicals used, warranty and operations information on equipment purchased, and other documents as needed. The procurement process should also include a method by which this information is shared with the rest of the organization.

Contractors: This is another commonly overlooked component of an organization's health and safety program. Each year hundreds of incidents occur in workplaces that can be directly attributed to actions performed by direct or third-party contractors working temporarily at a worksite. It is important that you consider how the relationship with your contractors is defined. This includes how your safety requirements are communicated, what hazards the contractor may introduce into the workplace, and how liabilities will be shared or transferred as appropriate.

Emergency preparedness: In spite of our best efforts, sometimes "it" happens – a bomb scare in the courthouse, a wreck involving a transit van, an employee collapsing in the tax office. All of these are real events, and the organization must be prepared ahead of time to deal with them. For a county, this emergency planning goes beyond emergency operations for community incidents, but includes what will be done internally to react to situations that may occur in county facilities involving employees and members of the public. Procedures, drills and plans should be well thought out, then practiced and rehearsed extensively so that they become second nature.

Coupled together, all of these elements have a common thread – they all involve situations when operations are not at a normal state, be it when a hazard is discovered, a new process is introduced, a new product is purchased, contractors begin working, or when something out of the ordinary happens in the workplace. The vast majority of incidents that occur in the workplace can be traced back to one of these components not being thought through or complied with.

The next installment will continue our discussion by dealing with three other critical pieces of the OHSMS system – training, communications and documentation.

As Risk Control Manager for the NCACC, Bob Carruth manages the operation of the Risk Control Team for the Risk Management Pools. The team assists members with development of safety policies and programs and identification of liability exposures and controls. Carruth is a Certified Safety Professional and is certified as Associate – Risk Management. A current Cabarrus County commissioner, he serves on the Board of Directors for Piedmont Behavioral Healthcare and the Water & Sewer Authority of Cabarrus County.